AEC Speaks Out Against Fischer’s Claims Dear DWM,
I am writing to voice our concerns with the recent article Energy Star® Loses Luster written by Mike Fischer on behalf of the Window and Door Manufacturers Association (WDMA) (see DWM, July 2005, page 16). While we respect the wide range of opinions about important programs like Energy Star, Fischer’s comments include an irresponsible and unjustified attack on the Aluminum Extruders Council
(AEC).

First, Fischer asserts that the AEC has no interest in promoting energy efficiency, and only seeks to protect the interests of the aluminum industry. We highly object to this irresponsible statement. Of course, all trade associations exist to benefit their members, but it is in the interest of our members to promote their higher value-added energy efficient products. Our members have helped expand energy-efficient technologies such as advanced thermal barrier frames, and offer products with the best available spacer and low-E glass technology. Our members are also involved in ongoing research to continue to improve the energy efficiency of commercial products while maintaining the necessary structural performance and durability required in these applications. We have also helped to advance the building codes in a responsible manner.

With regard to Energy Star, we believe the recently announced performance-based criteria to be a significant advancement for the program. Fischer claims that the new performance-based criteria are “lowering the bar” for energy efficiency. He seems to fail to understand that the entire point of the alternative performance-based criteria is that these combinations of window properties provide the same equivalent total energy performance as the current criteria. The technical analysis behind these criteria was performed by the experts at Lawrence Berkeley National Laboratory, together with technical input from all segments of industry. If a window has the same total energy performance as the current criteria, it should qualify for the program. Far from weakening the program, by including more products with equivalent performance, the new alternate criteria will strengthen the credibility and success of the program for both manufacturers and consumers. On the other hand, Fischer seems to believe it is preferable to exclude certain products even if they have equivalent overall energy performance, which raises concerns about competitive interests.

Fischer also claims that the new alternative criteria were developed based upon material interests. While the U.S. Department of Energy (DOE) takes into consideration many factors prior to making any decision, the beauty of performance-based criteria is that qualification is based on total energy performance, not material. In fact, it is the prescriptive criteria, that Fischer favors, that are not material neutral.

The original criteria favors certain products and materials which happen to fit a specific combination of U-factor and solar heat gain coefficient (SHGC), and excludes other products which may have the same overall energy performance but with a different combination of properties. In the end, it should not matter what framing material, glass, or spacer is used as long as the final product has the same total energy performance. It is for this reason that international window programs in Europe, Canada and Australia already use performance-based criteria. Similarly, nearly all of the U.S. Energy Star programs for other products besides windows use performance-based criteria rather than prescriptive design requirements. The new performance-based criteria helps advance the U.S. windows program towards that same goal.

Furthermore, the public record shows that a number of companies that manufacture both vinyl and aluminum products submitted public comments in favor of the performance-based approach. Fischer’s attacks are simply unfounded and biased.

With regard to concerns about simplicity, we would like to point out that these are alternative criteria. They will not affect any products which already qualify for the Energy Star program under the current criteria, and any manufacturer can simply continue with their current practice and ignore the new alternative criteria.

Finally, the DOE started developing the alternative performance-based criteria for Energy Star in May 2003. During that two year period, there were at least four requests for public comments through the DOE forum, yet Fischer and WDMA did not submit a single public comment. Fischer had plenty of opportunity to voice his concerns throughout the development process, yet failed to do so. The active participation of AEC, its members and other participants should be applauded for helping to advance the Energy Star program, whereas it is Fischer’s lack of participation that should be questioned.

Rand A. Baldwin, CAE
President
Aluminum Extruders Council

More Feedback to Columnist’s Views on Energy Star® Dear DWM,
I was surprised when I read an article in your magazine written by Michael Fischer. Some of the information presented in his article is either inaccurate or misleading. Fischer suggests that the DOE conforms to the pressures of the AEC, which is not accurate. If this is indeed true, how do you explain the creation of the South Central zone which initially had a U-Value of 0.65 and which was later changed to a 0.40? This change did not in any way benefit aluminum windows. These new values were made in an arbitrary way; not from any scientific study but rather through pressures from special interest groups (wood and vinyl). Another issue that Fischer did not clarify in his article is that in the new zone, the SHGC is more important than the U-Value.

In the name of saving energy, the aluminum industry has suffered. We cannot reverse this damage but I suggest that we should be realistic and accept what is in place now: compete fairly and stop the game of trying to destroy one at the expense of another. In our company, we manufacture aluminum and vinyl windows and we use each product for its own merits.

In my opinion, AEC has done nothing wrong nor have they attempted to bias Energy Star towards aluminum-framed products. In fact, AEC has focused on promoting aluminum products and the values they bring as an alternative to wood and vinyl. If Energy Star is truly dedicated to improve energy efficiency, I feel durability and structural integrity of a product must be taken into consideration as well as U-Values and the solar heat gain. Lasting energy savings must be the true objective for a program to be successful.

Ivan Paredes
Director of Engineering
General Aluminum Co.
Performance Based Versus Prescriptive BasedDear DWM,
I felt compelled to take the time to write to you due to an article penned by Michael Fischer in the July issue of your magazine. Fischer is quite misinformed on several points that he makes in his writings.

He states that the current DOE Energy Star® program is a performance-based program. Nothing could be further from the truth. It in fact was a prescriptive-based program. The new trade-offs will help it to become a performance-based program. Research would also tell him that almost all of the DOE Energy Star products fall into the performance-based criteria.

His comments on the AEC’s KAW program are not entirely in error, but he makes it out to be an initiative to lobby against energy savings. Not so; the Energy Star changes that take effect in September will allow the consumer to actually save energy in selected windows. Performance-based products will always allow the consumer the best option in energy savings. The DOE does not tell manufacturers how to get to a target, just to get there; that is what will now happen with Energy Star.

The DOE and their very capable thermal performance experts would not allow any industry group to alter their program to the detriment of energy savings. He is giving the AEC too much credit. The group conducted several months of intensive simulation work to rove the viability of a performance-based criteria. It did not prove out in all regions, thus the reason that not all regions are permitted to use the new system.

It is important that your regular contributors take the time to truly investigate all of the issues and facts before putting something in print, and even more important that you hold these contributors to a higher standard.